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Privacy Policy

This document informs you of the privacy policies of LDIC and the ways we ensure the protection of your privacy and the confidentiality of your personal information. This policy applies to LDIC’s individual clients, including persons who carry on business alone or in partnership with other individuals.

The privacy of our investors is very important to us. Set forth below are our policies with respect to personal information of clients and former clients we collect, use and disclose.

Collecting Information

When we collect information from you, we will explain what information we collect and how we intend to use it. This explanation is set out in the Privacy Agreement, which is included in the documentation you will receive when you open an account with LDIC.

In connection with our business offering, we collect and maintain personal information about clients. We collect your personal information to enable us to provide you with services in connection with your investments, to meet legal and regulatory requirements and for any other purpose to which you may consent in the future. Your personal information is collected from the following sources:

(a) new client application agreement or other forms that you submit to us;

(b) your transactions with us; and

(c) meetings and telephone conversations with you.

Why We Need Your Information

We ask for a variety of information when you open an account with us. Securities industry regulations demand we obtain a minimum amount of information about you so we can provide the proper level of service and supervision to your account. We may also base our recommendations about our products and services to you on the information you provide to us. For example, we may use your date of birth to identify you, or to determine your eligibility for products or services, which may be of benefit to a certain age group. We require your SIN in order to comply with certain Canada Customs and Revenue Agency reporting requirements. We may also use your SIN as a means of identifying you. Industry standards demand we know your financial information to help us identify products and services which are suitable for you, such as the use of margin in an account.

Products and Services

We will only share your information with others if authorized by you. Your consent to our providing information to other parties is optional and may be withdrawn by you at any time.

Third Parties

We may disclose your personal information to third parties, when necessary and to our affiliates in connection with the services we provide related to your portfolios:

(a) financial service providers, such as banks and others used to finance or facilitate transactions by, or operations of, LDIC

(b) other service providers to LDIC, such as accounting, legal, or tax preparation services

(c) taxation and regulatory authorities and agencies

With your consent, we may obtain information about you from third parties such as credit agencies. This information helps us assess your eligibility for certain products and services such as a margin account. Please remember if you do not agree to provide your consent for this, we may not be able to extend margin privileges to you. We may also, with your consent, provide your information to outside sources. For example, service providers whom we hire to do things like process your trades and send your month-end statements to you will have access to certain account information including your name and address in order to perform their required functions. We require our third party service providers to sign a privacy Agreement to help ensure they will protect the confidentiality of your information. We are also obliged to provide your information to regulatory bodies within the investment industry. We may also be required to disclose receipt of a valid Court Order or search warrant. We may also disclose your information to outside sources to help us collect a debt owed to us by you. As well, we may disclose your information as a result of a transfer of our business, should we decide in the future to sell off all or part of our business or to merge with another financial institution.

Unless you otherwise advise, by providing us with your personal information you have consented to our collection, use and disclosure of your information as provided herein. We collect and maintain your personal information in order to give you the best possible service and allow us to establish your identity, protect us from error and fraud, comply with the law and assess your eligibility for our products.

Protecting of Information

We have thorough security standards in place to protect your information against unauthorized access and use. If you access your account through an electronic means LDIC’s Online Viewing, we use passwords you alone should know. Our internet-based applications that use “cookies” will use only “session cookies”, which means the cookies will be erased from your computer as soon as your session is over. We also provide training to our employees so they will understand the need for confidentiality when dealing with your information. We retain your information only as long as we need it to service your account, or as long as industry regulations demand. When we no longer need your information, we will delete electronic records and destroy physical records.

We seek to carefully safeguard your private information and, to that end, restrict access to personal information about you to those employees and other persons who need to know the information to enable LDIC to provide services to you. Each LDIC employee is responsible for ensuring the confidentiality of all personal information they may access.

Your personal information is maintained on our networks or on the networks of our service providers accessible at 2130 - 130 King Street West, PO Box 399 Toronto, Ontario, M5X 1E2. Your information may also be stored in a secure off-site storage facility. You may access your personal information to verify its accuracy, to withdraw your consent to any of the foregoing collections, uses and/or disclosures being made of your personal information and may update your information by contacting LDIC at the following number: (416) 362-4141. Please note your ability to participate in LDIC’s business offering may be impacted should you withdraw your consent to the collection, use and disclosure of your personal information as outlined above.

Your Right to Access Information

Most of your information is in the form of account documentation and transaction records. You will receive copies of any documents you sign to open your account with LDIC. You will also receive copies of monthly or quarterly statements of your account, which detail all of the transactions that have taken place in your account during that period. If you have chosen to have access to your account electronically, i.e. through LDIC Online Viewing, you may also view your account transactions that way. If you require further details about your information, you may contact us at any time. Naturally, we will have to assess your request to ensure it does not contain references to other persons, or violate our legal privilege.

Accuracy of Information

Having accurate information about you will enable us to give you the best possible service. We expect you will provide us with updated information when you move or change telephone numbers, or have any other material changes in your information. If you detect any errors in information (such as the information appearing on your copy of your application form), please let us know immediately.

Your Right to Withdraw Consent

When you sign the documentation required to open your account, you will see that within that documentation is our Privacy Agreement. By opening an account with us, you are providing your consent for us to collect, use and release your personal information. If at any time you wish to withdraw this consent, please advise us. However, please note withdrawing consent may mean we will be unable to provide certain services to you. We will explain the consequences of withdrawing consent, should you choose to do so.

Online Services

As mentioned previously in this material, we do offer online services through our web site. While we may keep records of which web pages you visit while you are in our web site, or what you may download from our web site, we do so for statistical purposes only. We merely keep track of which pages are visited and do not take or use any personal information from you during your visit to our web site. When you send us an email, we learn your exact e-mail address as well as any other information you may have included in the e-mail. While we may use your e-mail address to reply to you, we do not make your e-mail address known to anyone outside our firm. We may use your e-mail address to advise you about products or services that may be of interest to you if you have asked us to put you on an e-mail mailing list. You may ask us to remove you from our mailing list anytime by using the “unsubscribe” instructions provided with each e-mail. We may also send certain required information to you via e-mail such as Shareholder Communication information if you have requested we do so. Again, you may cancel this at any time. Please keep in mind information sent via e-mail is generally unencrypted, so we would remind you not to send us confidential information via e-mail.

Addressing Your Concerns

We will address and respond to any of your concerns about our handling of your information.